Privacy Policy

Introduction

Custom PC Systems LTD having an address at Steliou Kyriakidi 45, Limassol, 3080, Cyprus (hereinafter, referred to as the “Company”, “us”, “we”, “our”) collects from the individual user (hereinafter, referred to as “you” or “your”) certain personal information through the website http://www.custompc.com.cy (hereinafter, referred to as the “Website”).

This Privacy Policy (hereinafter, referred to as the “Privacy Policy”) explains our procedures related to the collection and processing of personal information through the Website.

We are committed to ensuring that your privacy is properly protected. Should we ask you to provide certain information by which you can be identified when using the Website, then you can be assured that it will only be used in accordance with this Privacy Policy.

Personal data collection and processing through the Website is conducted in accordance with the data protection laws of Cyprus and the applicable EU laws.

Your Consent

When you visit the Website, we will ask you for your explicit express consent to our collection and processing of your personal data in accordance with this Privacy Policy (e.g., via a click on the button “I agree” or ticking a box). For the purposes of this Privacy Policy, the term “processing” refers to collection, storage, deletion, use, and disclosure of personal data.

What we collect

We adhere to data minimization principles. We collect and process only minimal amount of personal data that is strictly necessary for performing the operations requested by you through the Website (e.g., placing and processing orders), unless you decide, at your sole discretion, to provide additional personal data to us.

When you visit the Website, we will collect your IP address.

When you sign up for our newsletter by using the “Get our latest news & updates” functionality available on the Website, we will collect your email address.

When you purchase products through the Website or create a user account on the Website, we may collect the following personal data:

• First name;

• Surname;

• Email address;

• Physical address;

• Billing address;

• Username;

• Password;

• Company name;

• Phone number;

• Birth date; and

• Gender.

If you do not provide us with the requested personal data, we may not be able to process your purchase order and you may not be able to use the full functionality of the Website.

By using the Website, you acknowledge and agree to submit personal data that is up-to-date, true, accurate, current, and complete, and you shall update your personal data as soon as any changes in your personal data occur.

Personal data collected from third parties. We may receive some personal data from third parties, such as data authentication providers and social media service providers, if you access the Website through such providers. Please note that data processing of such providers is governed by their individual privacy policies. Please read carefully the applicable privacy policy and check your privacy settings in order to control the personal data you permit to send to us.

Sensitive data. Please note that we do not collect sensitive personal data (e.g., your health information, opinion about your religious and political beliefs, racial origins and membership of a professional or trade association), unless you decide, at your sole discretion, to provide such sensitive data to us through the Website.

What we do with the personal data we gather

We respect data protection principles and we collect and process the personal data only for the purposes for which personal data is provided.

If you provide your personal data for the purpose of obtaining quotes for the products and services sold through the Website, we will use your personal data to provide you with quotes for products and services for which you have expressed interest.

Your personal data provided during the process of purchasing products and services through the Website will be used to process and deliver your orders.

We may also use your e-mail address to send you information about products or services that are the same as or similar to those that you have ordered from us and that we think you may find useful. We will do so only if you have indicated that you do not object to being contacted for these purposes.

Your email address provided for subscribing for the “Get our latest news & updates” functionality will be used to deliver you a newsletter.

After obtaining your prior consent, we may use your personal data for market research purposes (i.e., to understand your needs and provide you with a better service). We may contact you for market research purposes by email, phone, fax or mail.

After obtaining your prior consent, we may send you promotional emails about new products, special offers or other information which we think you may find interesting.

At any time, you have the right to ask us to stop using your personal data for direct marketing purposes described above by:

• Clicking on the “Unsubscribe” link contained in any direct marketing material provided by us; or

• Contacting us using the contact details available at the end of this Privacy Policy.

The use of your personal data for the purposes that are different than the purposes mentioned above will be possible only if we obtain your prior express consent.

In case the Company is being sold partly or fully, the Company may also provide your personal data to a purchaser or successor entity.

Security

We adhere to current information security standards by employing information security tools, such as secured networks, pseudonymisation, encryption, as well as suitable physical, electronic and managerial procedures, for the purpose of protecting your personal data. We put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data.

However, due to the inherent risks of using the Internet, we cannot be liable for any destruction, loss, leakage, and falsification of personal data caused by circumstances beyond our reasonable control.

Please note that you are solely responsible for keeping online credentials, such as login details and passwords, in a private and secure manner. Under no circumstances shall we be responsible for unauthorized access and any damage whatsoever occurred due to your failure to protect your online credentials.

Minors

The Website cannot be accessed and used by users under the age of 18. However, we cannot distinguish the age of people accessing the Website. If a person under 18 has provided us with personal data without obtaining parental or guardian consent in advance, the parent or guardian may contact us requesting us to destroy or de-identify the personal data. Our contact details are specified at the end of this Privacy Policy.

Third party access to your personal data

The personal data provided by you for signing up for our newsletter will be used by our newsletter provider MailChimp, which adheres to data protection principles contained in this Privacy Policy. MailChimp is a USA company, which complies with the U.S.-EU Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the Member States of the European Union. If you would like to read MailChimp’s privacy policy, please visit http://mailchimp.com/legal/privacy/.

When you make payments through the Website, your payments will be processed by our third party payment processors, (i) PayPal (Europe) S.à r.l. et Cie, S.C.A. having an address at 22-24 Boulevard Royal, L-2449 Luxembourg and (ii) JCC Payment Systems LTD having an address at Stadiou 1, 2571 Nisou, PO Box 21043, 1500 Nicosia, Cyprus (hereinafter, collectively referred to as the “Third Party Payment Processors”). Our Third Party Payment Processors may collect payment information from you which is necessary to make the payments requested by you. Please note that we DO NOT store your credit/debit card information. Our Third Party Payment Processors handle all the steps in the payment process on their websites, including data collection and data processing.

We may pass on your personal information to other third parties if this is necessary in order to achieve the purpose for which you provided the personal information to us (e.g., to provide you with a quote).

Unless otherwise stated in this Privacy Policy, we will not pass on your personal information to third parties without first obtaining your prior written consent to do so.

Third party service providers that provide us with technical services, such as software developers, hosting, website, and storing providers, customer support and marketing partners, may have access to your personal data for the purposes of service provision. Please note that such third party service providers perform services on behalf of us and they may be located outside of your country of residence. The Company shall put reasonable efforts to assure that such third parties employ an adequate level of protection of personal data that is consistent with this Privacy Policy.

Some of the Company’s subsidiaries, affiliates, and third parties mentioned above, may be located outside of the European Union. We put reasonable efforts to assure that our subsidiaries, affiliates, and third party partners adhere to the privacy principles set out in this Privacy Policy an the applicable privacy laws.

With the exceptions of the cases mentioned above, we do not give your personal data to third parties, unless we are legally bound to do so.

We do not sell your personal information to third parties, and does not intend to do so in the future.

Accessing, correcting, and deleting personal data

We take reasonable steps to ensure that the personal data collected and processed by us is accurate, complete, and up-to-date. Thus, we ask you to keep your personal data as current as possible and update your personal data through your user account on the Website as soon as any changes in your personal data occur.

You have the right to access, modify, or delete your personal data that is processed by us. If you would like to do so, please send an email to the following email address sales@custompc.com.cy. We will answer your request as soon as possible but no later than 14 calendar days.

Retention period

We will keep your personal information for as long as it is necessary to provide you with the requested service. For example, if we collect your personal information to deliver the newsletter, your personal information will be kept until you unsubscribe from the newsletter services.

If your personal information is no longer necessary for the delivery of the requested services, we will delete it as soon as possible.

Links to other websites

Our Website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our Website, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Direct marketing and newsletters

If you sign up for our newsletter by using the “Get our latest news & updates” functionality available on the Website, we will regularly send you newsletters and other news, offers, and information that can be of interest to you.

After you purchase products from us, we may use your e-mail address to send you information about products or services that are the same as or similar to those that you have ordered from us and that we think you may find useful.

When you register a user account on the Website, you can opt in for receiving our newsletter and other direct marketing materials by expressing your preference.

From time to time, we may also use your personal data to contact you for market research purposes. We may contact you by email, phone, fax or mail.

At any stage, you have the right to ask us to stop using your personal data for direct marketing purposes by the following ways:

• You can click on the “Unsubscribe” link contained in any newsletter provided by us;

• If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by contacting us. Our contact details are indicated at the end of this Privacy Policy.

Amendment of this Privacy Policy

We reserve the right to amend this Privacy Policy from time to time by posting an amended version on the Website and sending you a notification by email or a message through your user account. Your continued use of the Website after posting such an amended version or receiving a notification will constitute your acknowledgment of the amendments and your consent to abide and be bound by the amended Privacy Policy. Please regularly review this Privacy Policy in order to be aware of new amendments.

Complaints

You have the right to submit a complaint about the way in which your privacy has been handled by using the contact details indicated above. After you submit such a complaint, we will send you an email within 5 business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe but no later than 2 weeks.

If you are not satisfied with our response, you have the right to lodge a complaint with Cyprian Commissioner for Personal Data Protection. More information is available at http://www.dataprotection.gov.cy.